FINANCIAL CONDUCT AUTHORITY (FCA)
Coronavirus and safeguarding customers’ funds: proposed guidance for payment firms
Our comments are based upon consultancy and operational engagements with payment service providers (PSPs) and insights gained anecdotally from involvement more generally with the industry.
Our comments are also shaped by public domain material relating to the administration proceedings relating to Ipagoo LLP (which traded as ipagoo).
Remittances to overseas families are a legitimate use of PSPs particularly by the socially excluded.
The current environment places this legitimate use of PSPs under stress
PSPs should plan for these stresses and be adequately capitalised.
The firm’s research and other publications on PSPs are appended to these comments.